Issue 2015-01 | February 2015 ISBN 978-92-79-45368-7, ISSN: 2363-3468

Competition State aid brief Occasional papers by the Competition Directorate–General of the European Commission

State aid to European : returning to viability Guillaume Adamczyk and Bernhard Windisch

Introduction In a nutshell From 2007 onwards, the European Union faced the most serious Since the beginning of the European financial crisis, EU financial crisis since its creation. The Commission played a very countries have provided €671 billion in capital and repayable active role in dealing with the European sovereign crisis, and loans and €1 288 billion in guarantees 1 to financial swiftly adapted the State aid framework to put in place an institutions in distress, subject to EU State aid rules. Between effective response to the financial crisis. The Commission made 2007 and 2014, DG Competition has taken more than sure that banks were restructured or resolved under State aid 450 State aid decisions, determining the restructuring or rules, which preserved financial stability and the integrity of the internal market. This laid the foundation for the banking system orderly resolution of 112 European banking institutions2. to be able to resume its pivotal role in providing credit to the real In this State aid brief, we evaluate the effectiveness of these economy. restructuring measures. The results are striking: Don't be afraid of the numbers… (1) Around 25% of the entire European banking sector has

been restructured under EU State aid rules. The Commission Since the beginning of the financial crisis , 112 banks in the EU, representing around 30% of the EU banking system by assets, reviewed State aid granted to some of Europe's biggest 3 financial institutions. Out of the top 20 European banks, the have received State aid . The aid provided in cash expenditure represents 5.4% of the EU's GDP in 2008 (or €671 billion in Commission approved aid to 12 banks, of which six were capital and loans injected into banks) and 10.3% in contingent subsequently restructured, five received aid through approved exposure (or €1 288 billion of liquidity and asset guarantees aid schemes, and one was orderly liquidated. provided to banks). To overcome the risks to financial stability, (2) This aid has paid off. Supported and restructured banks almost all Member States have made State aid available. In fact, are showing significant improvement in operational and risk in quite a few countries, more than half of the banking sector has indicators, and in funding and solvency positions. However, received State support4. The Commission approved restructuring the recovery is a time-consuming process. It is only towards plans for 56 of these banks, agreed on plans for orderly wind- the end of the restructuring period that the performance of down for 33 banks, and reviewed the viability of 14 others restructured banks converges towards the values of banks without further need for a restructuring plan. As of December that did not receive aid. 2014, the Commission was in the process of assessing the viability and restructuring of 9 banks. (3) Results from the recent asset quality review and stress test conducted by the ECB on the main European banks Has it worked? confirm these findings. Most banks under State aid control Because of the importance of the restructured banks to the successfully passed the test confirming their solvency. Ten European banking system and the significant amounts of aid banks under State aid restructuring that failed the exercise granted, it is essential to know how effective the EU-approved are only in the first couple of years of restructuring plan restructuring measures have been. It is critical to know whether implementation. If the Single Supervisory Mechanism accepts the restructured banks are returning to long-term viability all capital-generating actions implemented in 2014, only two without further need for aid, and especially whether they could of these banks will have a net capital shortfall, and one has announced recourse to private measures to fill the gap.

3 112 banks have been examined individually with respect to State aid received. This excludes cases receiving State aid under a governmental scheme but in amounts smaller than the relevant thresholds above which a separate notification would have been required. Note that the specific conditions for notification have evolved during the crisis.

4 Overall, 22 Member States provided aid to the financial sector. In Belgium, 1 Total of peak amounts of outstanding guarantees issued by each Member State. Cyprus, Greece, Ireland, Netherlands, Portugal and Slovenia, more than 50% of 2 Figures date from December 2014. the financial system by assets has received State support.

KD-AM-15-001-EN-N, doi 10.2763/593657 Competition State aid briefs are written by the staff of the © European Union, 2015 Competition Directorate-General and provide background to policy Reproduction is authorised provided the source is acknowledged. discussions. They represent the authors’ view on the matter and do More publications on: http://ec.europa.eu/competition/publications and not bind the Commission in any way. http://bookshop.europa.eu State aid to European banks: returning to viability | Competition State aid brief

withstand renewed stress in the banking system. This State aid What does long-term viability mean? brief presents answers to these questions5. According to the Restructuring Communication, "long-term viability is achieved when a is able to cover all its costs Viability requirements under State aid rules including depreciation and financial charges and provide an appropriate return on equity, taking into account the risk profile of 7 Three main pillars the bank. " In order to minimise costs to the taxpayer, it is essential to ensure that State aid is appropriately remunerated The Commission's assessment of bank restructuring plans under and eventually recovered by the State. To achieve this, banks the State aid crisis rules is built on three pillars6: must have the ability to generate a sustainable income and an appropriate return on equity. i. Restore long-term viability without further need for State support in the future, by restoring sustainable profitability The Commission examines a large number of elements in order and reducing risk; if this proves not possible, consider an to assess whether the bank will be able to generate sustainable orderly winding-down; income and manage costs and risks. The Commission conducts a fundamental review of the bank’s business model and identifies ii. Minimise the use of taxpayers' money, through the root causes of the bank's problems, finds the best path to an appropriate burden-sharing measures, including aid improved or new business model, and produces a technical remuneration and contributions by the bank, shareholders feasibility assessment and a stress scenario to ensure that the and junior creditors; bank can withstand shocks. The Commission also examines the quality of the bank's risk and credit management, and looks at iii. Limit distortions of competition through proportionate the bank's funding strategy and the development of its solvency remedies. Giving State aid to a particular bank can distort position. Last but not least, the Commission reviews the overall competition, as it gives the bank an advantage over its governance structure as well as the appropriateness of competitors. remuneration and incentive structures.

Restoring long-term viability is key The restructuring plan needs to demonstrate on the basis of all This brief focuses on restoring long-term viability of aided, viable these elements that the bank can return to sustainable banks and the convergence of their performance towards that of profitability within five years. The key elements of the new their non-aided peers. We assess banks based on their overall business model are laid down in legally binding commitments in performance, taking into account the full implementation of the a Commission decision approving State aid endorsing the decision including the restructuring plan, i.e. of the three pillars restructuring plan. The proper implementation of the restructuring mentioned above. plan and commitments contained in it is subsequently monitored by trustees, acting as the Commission's "eyes and ears". Throughout the crisis, the Commission has stressed the importance of financial stability when implementing State aid Performance of aided banks compared to rules. Especially at the beginning of the crisis, exceptional market conditions made it necessary to ensure that conditions attached peers before and after receiving State aid to State aid to systemic banks would not create disturbances in Here we examine the performance of viable banks that received the financial markets. This is why State aid rules initially aid following Commission-approved restructuring plans compared permitted relatively generous conditions for granting State aid. to the peer group of unaided banks. The comparison is done by These conditions have been progressively adapted and tightened looking at the performance of aid recipients in "year zero" when in order to reflect changing market conditions and the evolving they first received aid, and the relative pre-aid and post-aid nature of the crisis. developments8. The comparison is based on key performance indicators relating to developments in operative and risk Restoring viability was, and remains, a fundamental element of management, overall profitability and capital and funding assessing banks in need of State support. Maintaining unviable positions. banks on the market would further impair the financial system and monetary transmission mechanisms, and create a medium- Adjusting costs to long-term risk to financial stability. It would also distort We assessed changes in operative management using the competition by crowding out viable banks capable of lending 9 capital to the real economy. When a bank is assessed as unviable operating income over total assets and the cost-to-income ratio and unable to be turned around on the basis of a credible as indicators. Graph 1 shows how operating income of viable aid restructuring plan, it can receive liquidation aid in order wind recipients drops significantly in the period leading up to the need down in an orderly fashion. for state intervention. Following state intervention, there is a clear trend reversal, even though the pre-crisis levels and the comparative values for peers are not (yet) reached. Graph 2 displays the cost-to-income ratio and shows how in the year

5 The assessment is based on all aided banks that the Commission considered viable, i.e., capable of returning to long-term viability on the basis of their 7 Recital 13, http://eur-lex.europa.eu/legal- restructuring plans. It does not include those banks which received State aid to content/EN/TXT/PDF/?uri=CELEX:52009XC0819(03)&from=EN. enable their orderly winding-down. 8 For a detailed explanation of the methodology, please refer to the 6 http://eur-lex.europa.eu/legal-content/ methodological note in the annex. EN/ALL/;ELX_SESSIONID=m19STvHHQ8YFp0QCRJr35CY27hzlQv9bT3VJGHC1pLj 9 The normalisation by total assets is done to make banks of different sizes dmKYzQ26F!-1234597632?uri=CELEX:52013XC0730(01) comparable (see annex).

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immediately preceding state intervention it increases The declining values for RWA/Total Assets also reflect the significantly, mainly driven by important losses affecting some removal from the balance sheet of riskier assets with associated banks (base effect). However, the ratio is then reduced higher RWA values through mandatory deleveraging actions successively during the restructuring period, eventually falling to embedded in Commission-approved restructuring plans. Net loan the level of peers. balances are further reduced through provisioning as soon as NPLs are recognised in the accounts, at which point provisions Graph 1: Operating income to total assets have to be built11. Removing risky assets from the balance sheet and building provisions against recognised NPLs both lead to declining values of RWA/Total Assets12.

Graph 3: Risk Weighed Assets to total Assets

Graph 2: Cost to income ratio

NPLs (Graph 4) and coverage ratio (Graph 5) display an interesting dynamic: viable aid recipient NPL levels are initially lower than for peers, but then rise sharply, while the coverage ratio drops in the period leading up to State aid intervention. Receipt of State aid is then followed by stabilisation of NPL levels and a consistent rise in coverage ratio, bringing levels back in line with peers.

Lowering risks We assessed changes in balance sheet risk using the ratio of risk- weighted assets (RWA) over total assets, non-performing loan levels (NPL) and the coverage ratio10. A high RWA/Total assets ratio indicates a higher level of risk taken per assets on the balance sheet. Following regulatory changes during the crisis period, Graph 3 shows how the value of this ratio in the banking sector has generally been decreasing, mainly due to greater requirements for liquidity buffers, which can be enhanced by investing in high-quality, low-risk liquid assets. In spite of the general persisting trend, most aided banks tend to have started out with much riskier balance sheets.

It is important to note here that these values tend to come close 11 "Recognition" is a technical accounting term which refers to the acknowledgment to the levels of peers, even though the main reduction happens of non-performing loans in the official balance sheet. In turn, recognition requires setting aside money from profits for the expected losses from these already before the intervention. non-performing loans. "Provisions" is the technical accounting term for that money which on the balance sheet decreases the value of the outstanding loans. 12 This argument is based on the standard approach for calculating RWA. A similar 10 The coverage ratio is the ratio between loan loss provisions and non-performing argument, although more complex, can be made also for the Internal Rating loans. Based approach.

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Graph 4: Non-Performing Loan ratio This trend shows that the restructuring plans, and the organisational, behavioural, efficiency and cost-funding measures they comprise, are supporting and driving the successful turnaround of the State aided banks.

Graph 6: Return on Equity ratio

Graph 5: Coverage ratio

Enhancing solvency We assessed changes in solvency and funding using the Core Equity Tier1 Capital (CET) Ratio and the Loan-to-Deposit (LtD) ratio. Here, it is important to note that restructured banks start from a much riskier position than their peers on both accounts, solvency as well as funding. Restructured banks have a lower capital position overall to start with, and, at the same time, a much higher Loan-to-Deposit ratio, indicating greater reliance on wholesale funding. While the weaker capital position is very likely linked to profitability issues, the weaker funding position is most likely linked to the strong credit growth leading up to the crisis, very often funded via the wholesale market. The trend reversal in the Loan-to-Deposit ratio following state intervention is very A likely explanation is that (some) banks initially tend to delay positive. It is achieved by reducing excessive loan books – and recognition of non-performing loans. Supervisory guidelines, related risks – compared to peers. The peak at year zero is asset quality reviews and stress test exercises in programme associated with some deposit outflows which are usually countries and other vulnerable Member States can speed up reversed following the state intervention. For the capital ratio, the balance sheet recognition of NPLs. However, the increased speed public capital injection usually occurs around the same time as of NPL recognition often does not allow for offsetting accounting losses related to NPLs are realised (for example through Impaired provisions on NPLs to be built quickly enough, particularly in a Asset Measures). situation of economic crisis where profits and the capital situation are under heavy pressure. The time lag in these Graph 7: Loan to deposits ratio offsetting processes leads to losses which have to be taken immediately, even though coverage ratios are still insufficient, which contributes to the need for state assistance. In order to account for the different time scales of these two processes, most State aided banks are given time to clean up their portfolios gradually, without putting financial stability at risk.

Restoring profitability The overall profitability situation, assessed using Return on Equity (RoE), again shows the very high losses (negative RoE) suffered the year prior to the state intervention, and the cost of sorting out rising NPL levels afterwards. It is encouraging to see profits coming roughly in line with peers from the middle of the restructuring period onwards and becoming slightly positive towards the end of the observation period.

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Graph 8: Core equity capital ratio Table 1: Participating banks with a shortfall

Capital Capital shortfall Country Bank shortfall (€ post mitigating billion) measures (€ billion) BE AXA Bank Europe 0.2 0.0 IT Banca Popolare dell'Emilia Romagna 0.1 0.0 IT Banca Popolare di Sondrio 0.3 0.0 IT 0.7 0.0 CY 0.9 0.0

FR Caisse de Refinancement de l’Habitat 0.1 0.0

IT 0.4 0.0 DE Münchener Hypothekenbank 0.2 0.0 IT Veneto Banca 0.7 0.0 IT Banca Popolare di Milano 0.7 0.2 CY 0.3 0.2 IT Banca Popolare di Vicenza 0.7 0.2

IT 1.8 0.8 EI permanent tsb 0.9 0.9 Results from the Comprehensive Banks under SA / restructuring Assessment confirm findings CY Cooperative Central Bank 1.2 0.0 SP Liberbank 0.0 0.0 During 2014, the European Central Bank (ECB) conducted a EL 0.7 0.0 comprehensive assessment of 130 main European banks, SI Nova Kreditna Banka Maribor3 0.03 0.03 consisting of an in-depth Asset Quality Review (AQR) and a Stress SI Nova Ljubljanska banka3 0.03 0.03 13 Test. The results were published on 26 October 2014 . AT Oesterreichische Volksbanken 0.9 0.9 EL 3.4 0.0 Of 25 banks failing the comprehensive PO Banco Comercial Português 1.1 1.2 assessment, 10 were already in restructuring EL Eurobank 4.6 0.0 under State aid control IT Monte dei Paschi di Siena 4.3 2.1 In the comprehensive assessment, 25 banks were identified with Banks under SA / orderly liquidation a capital shortfall either under the AQR or in the Stress Test. Of BE 0.3 0.3 these 25 banks, ten had been subject to a restructuring decision Total 24.6 6.8 under State aid control14. Only five of these banks displayed a o/w Banks under SA restructuring 16.2 4.2 net capital shortfall after taking into account capital-generating Source: European Central Bank / DG Competition mitigating measures implemented through private means in 2014 and approved by the SSM. Three of the five banks had implemented additional measures during 2014, which were not Conclusion recognised by the SSM as mitigating measures during the 15 comprehensive assessment, but could still reduce capital need if We have shown that the banking restructuring plans approved recognised as part of the capital raising plan. The remaining two by the Commission under State aid rules have helped to save banks have announced their intention to cover the capital many European banks. The data shows significant improvement shortfall by private means subject to successful implementation. in operational and risk indicators, and funding and solvency positions. Only a few years after commencing a Commission- Two points are important to keep in mind: (1) the fundamental monitored restructuring scheme, recipients of aid start prerequisite of long-term viability is the ability of the bank to converging towards their peers. This suggests that in general, finance itself at market conditions. All but two of the ten banks banks that received aid during the financial crisis have bounced restructuring under State aid control have already raised the back after implementing a considerable part of their restructuring plans, and can today be considered to be as healthy as ordinary required capital through private means. (2) All ten banks 16 restructuring under State aid control are in the early bank implementation phase of their restructuring plan (year two or earlier). As we have showed in section three above, restoring viability takes time - this means a failure in year one or two of the implementation is potentially less of a problem than a failure in year four or later, providing, of course, the bank does not need to resort to further State aid and is able to meet the capital requirements through private means.

13 For detailed results, please consult the ECB/SSM website: 15 Please note that these conclusions are made on aggregate level and cannot be https://www.bankingsupervision.europa.eu/banking/comprehensive/html/index.en.html extrapolated to every individual case. 14 In addition, one bank, Dexia, has been subject to a liquidation decision and has 16 The authors would like to thank Sophie Bertin-Hadjiveltcheva, Anna Jarosz-Friis accordingly been freed from the obligation to raise capital. and Irmfried Schwimann for their valuable contributions.

5 State aid to European banks: returning to viability | Competition State aid brief

Annex I - Methodological note (10) The aggregation of data in the different groups has to contend with a number of particular issues: The Sample a. Aggregation over a wide range of different bank sizes b. Holes and discontinuities in the data time series (1) The Sample consists of 175 banks which fulfil at least one of c. Time series of data which can take positive and negative the following conditions: values (e.g. RoE) a. The bank is part of those banks for which supervision will d. For the category of State aided banks specifically, aid be taken over by the SSM in November 2014 as published reception in different years by the ECB. b. The bank is part of the concurrent stress-test exercise as Aggregation methodology published by the EBA. (11) In order to address the issues pointed out in point (10), the c. The bank is an independent public or private entity with a following methodology has been developed: balance sheet of greater than 10bn at the last available a. Using only dimensionless quantities (ratios) for which filing in Bloomberg. banks remain comparable independent of the differences d. At least one State aid decision has been taken on this in their respective sizes. bank in the years between 2007 and 2014. b. Focusing on year-over-year change rates when

calculating averages to exclude biases from incomplete (2) Dedicated state development banks are excluded from the time series in the sample. study. c. Developing a shifted weighted average approach resulting in corrected averages without biases from either crossing Data items & quality between negative and positive values as well as (3) Data was sourced from Bloomberg. incomplete time series. d. Re-defining the time scale as relative to the year of (4) Historical time series were taken for the years 2002 to 2013. It reception of State aid. has to be noted that not all banks full-year results for 2013 are available via Bloomberg at the date of this publication. (12) Following from this methodology, the time series for all State aided banks were re-aligned along the year when each bank (5) Data was subjected to a sensibility check and some obvious received State aid – the "year 0" (e.g. Bank1 receiving aid in errors were corrected (for example, figures provided in billions 2008 and Bank2 in 2012, the respective time series would be: where the base unit is millions). for Bank1 year 0 (2008), and correspondingly -1 (2007), -2 (2006), etc. and 1 (2009), 2 (2010), etc., for Bank2 year 0 (6) Various time series contain discontinuities / "holes" which can (2012), and correspondingly -1 (2011), -2 (2010), etc. and 1 be exacerbated by, for example, banking sector consolidation (2013), no year 2 as no data is available for 2014 as yet). From activity seen, for instance, in Spain over the recent years. We the example, it should become clear why data is becoming did correct these, discontinuities, apart from the most obvious more scarce for relative years >0 which is why a cut off was cases (for example, renaming of banks). introduced at year 4 (2013 for banks having received aid in 2009 and 2012 for banks having received aid in 2008). This (7) All ratios in the study were calculated based on the underlying reflects the scarcity of data available for aggregation in any balance sheet reporting figures. Bloomberg's pre-calculated further points. ratios were only used to cross-check with our own calculated values. (13) Using these re-aligned time series, the data is aggregated using the shifted weighted average approach mentioned in Sample aggregation (11)c. In addition, the decision was taken to use averages (8) The sample was separated into two main groups for the weighted with the total balance sheet size for all data items. purpose of the study: banks which had received State aid as This was done in order to emphasize the importance of the determined by at least one decision having been taken on the performance of bigger banks relative to the overall system. bank between 2007 and 2014 (State aided banks/aid recipients) and other banks headquartered in Europe (Peers). (14) An additional issue introduced by the re-alignment of time series for aided banks is that Peers can no longer be (9) Using the Commission decision as indicator for the presence of aggregated correspondingly in a simple way. In order to get to State aid tends to – if anything – underestimate the aid a benchmark from the data for Peers, the following process has provided because it will exclude State aid provided in the form been followed: of aid schemes unless the aid received under a scheme was a. Averages have been calculated on the original time series such that it also necessitated an individual Commission for Peers according to method (11)c. approval later. This excludes in particular some banks from the b. In order to arrive at a value for Peers in year 0 (or -1, -2, aided category which received usually small amounts of capital …, 1, 2, …), a weighted average over values from different early on in the crisis (e.g. under the French and Danish aid real time years has then been taken. schemes in 2008/2009). The weights used in this average correspond to the total balance sheet size of aided banks which had the relevant combination of real time year and relative year.

6 State aid to European banks: returning to viability | Competition State aid brief

Annex II - Sample

Austria LANDESBANK BERLIN HOLDING AG BANK NEDERLANDSE GEMEENTEN ALLG SPARKASSE OBEROESTERREI LANDESBANK HESSEN-THURINGEN COOPERATIEVE CENTRALE RAIFFE BAWAG P.S.K. BANK FUER ARBEI LANDESBANK SAAR ING BANK NV BANK AG LANDESKRED BADEN-WUERTT FOER NEDERLANDSE WATERSCHAPSBANK HYPO ALPE ADRIA BANK INTL AG MUENCHENER HYPOTHEKENBANK NIBC BANK NV HYPO TIROL BANK AG NORDDEUTSCHE LANDESBK GIROZ SNS REAAL KOMMUNALKREDIT AUSTRIA AG NRW.BANK VAN LANSCHOT NV-CVA OBERBANK AG OLDENBURGISCHE LANDESBANK AG Poland OESTERREICH VOLKSBANKEN-PART PORTIGON AG ALIOR BANK SA RAIFFEISEN ZENTRALBNK-PART A SPARKASSE KOELNBONN BANK BPH SA RAIFFEISENLANDESBANK NIEDERO VOLKSWAGEN BANK GMBH BANK HANDLOWY W WARSZAWIE SA RAIFFEISEN-LANDESBANK STEIER WGZ-BANK AG WESTDEUTSCHE GEN BANK OCHRONY SRODOWISKA SA RAIFFEISENLANDESBK OBEROESTE WUESTENROT & WUERTTEMBERG GETIN NOBLE BANK SA Belgium Greece PKO BANK POLSKI SA AXA BANK BELGIUM SA AGRICULTURAL BANK OF GREECE Portugal BELFIUS BANK & INSURANCE A.E. BANCO BPI SA.- REG SHS DEXIA SA ATTICA BANK SA BANCO COMERCIAL PORTUGUES-R KBC GROEP NV EMPORIKI BANK OF GREECE SA BANCO ESPIRITO SANTO-REG Bulgaria SA BANIF - BANCO INTERNACIONAL CB FIRST INVESTMENT BANK AD NATIONAL BANK OF GREECE CAIXA ECONOMICA MONTEPIO GER CORPORATE AD PIRAEUS BANK S.A CAIXA GERAL DE DEPOSITOS-REG Cyprus PROTON BANK SA Spain BANK OF CYPRUS PUBLIC CO LTD TT HELLENIC POSTBANK S.A. BANCO BILBAO VIZCAYA ARGENTA PUBLIC C Hungaria BANCO DE SABADELL SA HELLENIC BANK PUBLIC CO LTD FHB MORTGAGE BANK PLC BANCO DE VALENCIA SA OTP BANK PLC BANCO GALLEGO SA AMAGERBANKEN A/S Ireland BANCO MARE NOSTRUM SA A/S PLC BANCO POPULAR ESPANOL FIH ERHVERVSBANK A/S SA FIONIA HOLDING A/S IRISH BANK RESOLUTION CO/OLD SA HAANDVAERKERBANKEN-NEW PERMANENT TSB GROUP HOLDINGS SA -REG ULSTER BANK IRELAND LTD CAJA DE AHORROS DEL MEDITERR NYKREDIT BANK AS Italy CAJA ESPANA DE INVERSIONES S BANCA CARIGE SPA CAJA ZARAGOZA ARAGON Y RIOJA BANK A/S BANCA DELLE MARCHE CAJAS RURALES UNIDAS SCC VESTJYSK BANK A/S BANCA MONTE DEI PASCHI SIENA CATALUNYA BANC SA BANCA POPOL EMILIA ROMAGNA SA AKTIA BANK OYJ BANCA POPOLARE DELL'ETRURIA BANK FINLAND ABP BANCA POPOLARE DI BARI SCRL LIBERBANK SA OP-POHJOLA OSK BANCA POPOLARE DI MILANO NCG BANCO SA France BANCA POPOLARE DI SONDRIO UNICAJA BANQUE PSA FINANCE SA BANCA POPOLARE DI VICENZA Slovenia BNP PARIBAS BANCO POPOLARE SC ABANKA VIPA DD CAISSE REFINANCEMENT L'HABIT BCC ROMA BANKA CELJE CREDIT AGRICOLE SA CASSA DEPOSITI & PRESTITI NOVA KREDITNA BANKA MARIBOR CREDIT IMMOBILIER DE FRANCE SPA NOVA LJUBLJANSKA BANKA DD CREDIT MUTUEL GROUP CREDITO VALTELLINESE SCARL PROBANKA D.D.-PFD GROUPE BPCE ICCREA BANCA SPA SID BANKA DD LJUBLIJANA Sweden SOCIETE DE FINANCEMENT LOCAL MEDIOBANCA SPA KOMMUNINVEST I SVERIGE SOCIETE GENERALE SA UBI BANCA SCPA LANSFORSAKRINGAR BANK AB Germany SPA NORDEA BANK AB AAREAL BANK AG UNIPOL BANCA SPA SKANDINAVISKA ENSKILDA BAN-A BAYERISCHE LANDESBANK VENETO BANCA SCPA SVENSKA -A SHS AG Lithuania AB - A SHARES DEKABANK DEUTSCHE GIROZENTRA UKIO BANKAS United Kingdom DEUTSCHE APOTHEKER- UND AERZ Luxembourg PLC AG-REGISTERED BANQUE ET CAISSE D'EPARGNE D BRADFORD & BINGLEY PLC DZ BANK AG DEUTSCHE ZENTRAL- BANQUE INTERNATIONALE A LUXE HSBC HOLDINGS PLC HAMBURGER SPARKASSE AG ESPIRITO SANTO FINL GROUP SA PLC HSH NORDBANK AG KREDIETBANK SA LUXEMBOURGEOI NRAM PLC HYPO REAL ESTATE HOLDING AG Malta ROYAL GROUP IKB DEUT INDUSTRIEBANK AG BANK OF VALLETTA PLC SKIPTON BUILDING SOCIETY KFW Netherlands STANDARD BANK PLC KREISSPARKASSE KOELN ABN AMRO BANK NV PLC LANDESBANK BADEN-WUERTTEMBER AEGON NV

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